Forgot to Record a Cash Withdrawal in an RRO or PRRO: What to Do

If the cashier forgot to record a cash withdrawal through a cash register (RRO) or software cash register (PRRO), first count the money and check whether the shift has been closed. If the cash is still on site and you are withdrawing it now during an open shift, record the actual withdrawal. If the money has already been taken away, document the circumstances and discrepancy, give the documents to the accountant, and ask technical support how to proceed with the cash register in its current state.

After a fiscal report receipt—a Z-report—has been generated, you cannot add a cash withdrawal to the closed shift or record it retroactively. On the next day, a cash deposit must reflect only the cash that is actually still at the place of settlement. Removing cash does not change the amount of sales: you do not need to record a product return, repeat sale, or fictitious deposit or withdrawal for this purpose.

Which transaction the cashier missed

For a store in Ukraine, the applicable rules are set out in Ukrainian Law No. 265/95-VR of 6 July 1995, the procedures for using RROs and PRROs, and the Regulation on Cash Operations in the National Currency in Ukraine. To handle the mistake correctly, distinguish these three actions, each of which serves a different purpose.

The requirement to record cash deposits and withdrawals unrelated to settlement transactions is set out in Clause 6, Section III of the Procedure for Using RROs and Clause 9, Section IV of the Procedure for Using PRROs. In both documents, a cash withdrawal concerns an amount removed from the place of settlement.

The place of settlement is defined in Article 2 of Law No. 265/95-VR. Therefore, when checking the cash, include all the money at that location, including cash kept for change. A transfer of money from a drawer to another storage location should be assessed in light of how the store actually operates.

A cash withdrawal does not reduce sales revenue. If customers paid for goods and the cashier transferred the cash received to the central cash desk, the sales amount remains unchanged. Only the place where the money is held and the person responsible for it have changed.

What to check before taking any action in the software

We recommend that the owner or senior cashier and the cashier document the state of the cash desk before moving any more money. This will help establish the cause of the discrepancy and prevent a duplicate transaction.

1. Count the cash. Record the actual amount, identifying separately the balance for change and the money intended for transfer.
2. Check the shift. Find out whether it is open, whether a Z-report has already been generated, for which date, and whether transactions for the next shift have begun.
3. Review the cash register documents. Check cash deposits and withdrawals, sales, returns, and payment methods. If a document did not print or the software showed an error, first establish whether the transaction was nevertheless registered.
4. Determine where the money is. It may still be with the cashier, have been transferred to the central cash desk or a responsible person, or already have been deposited at a bank.
5. Gather supporting evidence. Find transfer documents, cash orders, bank receipts, and entries in the internal software. Compare their amounts, dates, and times.

Use this calculation sequence for reconciliation: starting cash plus actual deposits and cash received from customers, minus cash refunds and actual withdrawals. Card payments do not increase the physical cash in the drawer. Count each amount only once.

What to do depending on the shift status and where the money is

The shift is open and the money has not been taken away

If you had only planned to withdraw the money and it is still on site, record a cash withdrawal for the amount you are actually transferring now. Document the transfer in accordance with your company’s procedures and check the balance afterward. Leave some cash for change if necessary.

Illustrative example. The cash desk holds UAH 9,800, of which UAH 800 must remain for change. The cashier now transfers UAH 9,000 to the central cash desk and records a cash withdrawal of UAH 9,000. The actual balance is UAH 9,800 − UAH 9,000 = UAH 800. This does not change the sales amount.

If the money was already taken away earlier, even during the open shift, first follow the procedure for documenting the missed cash movement described below. Do not record a second physical withdrawal of the same amount.

A Z-report has been generated and the cash remains on site

Generating a Z-report does not confirm that the cashier transferred the money. If the cash remains at the place of settlement, the absence of a cash withdrawal record does not mean that you should record a withdrawal that did not happen.

Before the first settlement transaction after the Z-report, record a cash deposit for the amount actually held at the place of settlement, as required by Clause 6, Section III of the Procedure for RROs or Clause 9, Section IV of the Procedure for PRROs. If you then decide to transfer the money, record a cash withdrawal when that actual transfer takes place.

Illustrative example. UAH 7,500 remained at the place of settlement after the shift was closed. The next day, before the first sale, the cashier records the actual balance as a cash deposit. The cashier then transfers UAH 7,000 and records a cash withdrawal for that amount. UAH 7,500 − UAH 7,000 = UAH 500 remains for change.

If the first sale of the next shift has already taken place without the required cash deposit, document that circumstance separately. A later transaction will not change the time of the sale that has already been recorded. Agree with the accountant and technical support on how to proceed with the actual balance.

The money has already been withdrawn, but the cash withdrawal was not recorded

Document how much cash is missing from the place of settlement, who received it, and where it is now. If there is a transfer document or bank receipt, include it in the reconciliation materials. The absence of a cash withdrawal record and the absence of transfer documents are separate circumstances that must be examined.

Do not record a cash deposit for money that is no longer at the place of settlement and then record a withdrawal for the same amount. This would create records of a movement that did not actually occur. Similarly, do not open a new shift just to create the appearance of a withdrawal made the previous day.

Give the accountant the count results, the cashier’s explanation, the Z-report, and documents showing the actual transfer. The accountant must determine what actions are needed in cash and accounting records. Contact the RRO service center or the PRRO provider about the cash register’s current state: provide the model or software solution, the date and shift number, the amount of the discrepancy, and a list of transactions already registered. Technical actions must take into account where the money actually is.

Illustrative example. According to the cash register documents, there was UAH 12,000 before the withdrawal. The cashier transferred UAH 11,000 to the central cash desk but did not record the cash withdrawal. UAH 1,000 remained on site, and the discrepancy is UAH 12,000 − UAH 1,000 = UAH 11,000. These circumstances must be supported by documents. The next day, you cannot record a deposit of the full UAH 12,000 when only UAH 1,000 is actually there.

Why a closed Z-report cannot be corrected

Under Article 2 of Law No. 265/95-VR, fiscal functions provide for the impossibility of changing summary information on the volume of settlement transactions. For PRROs, Clause 5, Section IV of the relevant Procedure provides for one fiscal report receipt per shift; to close the shift, the cashier generates it and submits it for registration to the fiscal server.

A document created in the next shift does not supplement the previous Z-report. Changing the date on an internal document in the retail software does not change fiscal data that has already been registered.

A missed cash withdrawal is not a product return or an erroneous sale. Therefore, do not create a fictitious return, sale, or cancellation of a settlement to change the cash balance. Such actions would add inaccurate information about settlements with customers to the original error.

Does a Z-report reset the cash balance?

Do not assume that all RROs and PRROs display the balance after a Z-report in the same way. Check the documentation for your specific model or software solution and establish which figure you are seeing: the balance in the cash register, the amount for the current shift, or the balance in the internal accounting software.

The technical behavior of the counter does not change the actual amount of money or the requirements for recording cash deposits and withdrawals. If the software carries the balance forward, ask the provider how it records cash before the first settlement after the Z-report and how to verify the corresponding document. This helps prevent the same amount from being counted twice.

If the store does not accept, dispense, or hold cash at the place of settlement at all, there is no basis for a cash deposit or withdrawal. Cash held for change must be counted even when current customers pay for goods by card.

What documents to prepare and what to assign to the accountant

We recommend preparing a cashier’s memo or reconciliation report describing what actually happened. State the date and time the error was discovered, the cash register, the shift, the actual balance, the expected amount, the discrepancy, the time the money was transferred, and the recipient. Add an explanation of why the transaction was missed and a list of supporting documents. This document helps reconstruct events, but does not by itself remedy the violation.

For a legal entity, the accountant must check how cash is recorded and whether the company is required to keep a cash book. Clauses 11 and 39 of National Bank of Ukraine Regulation No. 148 distinguish between enterprise cash desks, units that keep a cash book, and units that operate without one. Recording a cash deposit or withdrawal does not replace all documents required for the particular accounting method.

• If the company’s central cash desk receives the money, check that the receipt has been properly documented and entered in its cash book.
• If the cash was deposited at a bank, retain the document required by Clause 29 of Regulation No. 148: depending on the deposit method, this may include a bank receipt, a self-service terminal receipt or slip, or an accompanying cash order for a bag containing valuables.
• If several cashiers work at the company under a senior cashier, account for the transfer of cash with signatures in the relevant book, as required by Clause 43 of Regulation No. 148.
• If an actual shortage or surplus is found, the manager and accountant must arrange an investigation into its causes and document the results. Clause 46 of Regulation No. 148 sets out the procedure for an inventory of an enterprise’s cash desk.

Record current receipts and disbursements in the cash book, if keeping one is mandatory, using the appropriate documents on the day the money actually moves. Under Clauses 32 and 40 of Regulation No. 148, receipts and disbursements based on cash orders are made on the day the orders are prepared, and entries are made on the day the money is received or paid out. Give the accountant details of a missed past movement so the accounting records can be properly corrected; do not document it as a new transfer that did not happen today.

What differs for an individual entrepreneur and a legal entity

An individual entrepreneur (IE) does not keep a cash book. Under Clause 14 of Regulation No. 148, an entrepreneur is also not subject to a cash limit or deadlines for depositing cash revenue. These rules apply to IEs whether or not they use the simplified tax system. The entrepreneur records income received in accordance with the rules referenced in Clause 11 of Regulation No. 148.

However, an entrepreneur who uses an RRO or PRRO must comply with the rules for recording cash deposits and withdrawals. Exemption from keeping a cash book and from the cash limit does not allow the entrepreneur to skip recording an actual cash withdrawal.

A legal entity must separately check its cash limit. Clauses 14–15 and 50 of Regulation No. 148 provide for setting the limit, and under Clause 53 an unset limit is considered zero. Recording a cash withdrawal through the cash register does not by itself prove that the money was deposited at a bank or that the cash limit was observed.

Before concluding that the cash balance exceeds the limit, the accountant must check which exceptions apply. In particular, Clause 54 sets out conditions for depositing excess cash on the bank’s next working day or using it the next day for the company’s needs; separate deadlines apply to receipts on weekends and public holidays. Clause 49 addresses a failure to collect cash caused by the collection provider, and Clause 18 provides special deadlines for holding funds for specified payments, including wages. Each exception must be supported by the circumstances and documents.

Is there a fine for a missed cash withdrawal?

First establish the specific violation and the applicable liability provision. Clause 1, Article 17 of Law No. 265/95-VR provides for sanctions for conducting a settlement for less than the full amount, failing to conduct a settlement through a fiscal cash register, failing to issue the appropriate settlement document, and other actions expressly listed there. The amounts are 100% of the sale amount involved for the first violation and 150% for each subsequent violation.

These percentages cannot automatically be applied to the amount of a missed cash withdrawal. The withdrawal of money itself is not a sale. Article 17 does not set out a separate financial sanction expressly described as a fine for failing to record a cash withdrawal. At the same time, Article 26 provides for administrative liability of officials and employees for violations of the Law’s requirements, and the review may reveal separate violations of cash accounting rules. Therefore, the mere existence of an explanatory memo does not justify promising that there will be no liability.

For territorial exemptions, check Clause 14, Section II of Law No. 265/95-VR. It applies to specified violations committed from 1 October 2023 when selling goods and providing services in temporarily occupied territories and territories of active or possible hostilities, until the relevant dates in the official list. The exemption does not cover violations of settlement procedures in the sale of excisable goods. A reference to martial law alone is not sufficient for exemption from liability.

Cash withdrawal and cash reconciliation in Torgsoft

To use a PRRO in Torgsoft, activate the additional “Програмний РРО” (“Software RRO”) function for the required number of workstations and configure the cash register and cashier key. The official guide to adding a PRRO lists “Внесення готівки” (“Cash Deposit”) and “Вилучення готівки” (“Cash Withdrawal”) among the receipt operations, as well as report generation. The “Операції з чеками” (“Receipt Operations”) section in the guide covers system actions intended for system administrators who are troubleshooting PRRO issues. We recommend agreeing with the administrator or technical support on how to record actual cash deposits and withdrawals at the cashier’s workstation.

In Torgsoft’s internal accounting, the “Інкасація” (“Cash Collection”) action reduces the cash desk balance by the specified amount, while “Здати виручку” (“Hand Over Revenue”) transfers money to another cash desk for further accounting. The financial document has a “Провести операцію через фіскальний реєстратор” (“Process the transaction through the fiscal cash register”) toggle, which appears when a fiscal cash register is configured at the workstation. When the toggle is enabled, creating the document also records a deposit or withdrawal and prints the corresponding receipt. These conditions are described in the “Фінансовий документ” (“Financial Document”) help page. During reconciliation, check both the internal document and the transaction result in the cash register.

To find a discrepancy, compare the documents for the relevant cash desk and period against the actual cash. The “Реалізація” (“Sale”) form provides a denomination-by-denomination check with saved results; whether the seller can see the total and discrepancy depends on access settings. The procedure is described in the “Реалізація” (“Sale”) help page. In the store’s instructions, agree on how to check the balance, document an actual transfer, and verify the cash withdrawal document before the end of work.

What to include in daily cash desk controls

1. Assign an employee to check the actual cash and transfer documents.
2. Before each withdrawal, determine the amount, recipient, and balance to be left for change.
3. Record an actual withdrawal as a cash withdrawal and check the result in the cash register.
4. Document transfers of money and current entries in any books your business is required to keep.
5. Before the Z-report, reconcile cash, recorded cash deposits and withdrawals, and internal documents; where settlement transactions take place, ensure that a fiscal report receipt is generated daily.
6. Before the first sale after a Z-report, check the actual balance and confirm that it has been recorded as a cash deposit.
7. Refer every discrepancy to the responsible person with the documents and an explanation of the circumstances.

Official regulatory sources

• Law of Ukraine “On the Use of Cash Registers in Trade, Catering, and Services” of 6 July 1995 No. 265/95-VR: Article 2, Clauses 1–3 and 9 of Article 3, Clause 1 of Article 17, Article 26, Clause 14, Section II.
• Order of the Ministry of Finance of Ukraine “On Approval of Procedures for the Registration of Cash Registers and Settlement Transaction Record Books” of 14 June 2016 No. 547: Clauses 4–6, Section III of the Procedure for registering and using RROs for settlements for goods and services approved by the Order.
• Order of the Ministry of Finance of Ukraine “On Amendments to the Order of the Ministry of Finance of Ukraine of 14 June 2016 No. 547” of 23 June 2020 No. 317: Clauses 1, 3, 5, and 9, Section IV of the Procedure for registering, maintaining the register of, and using PRROs approved by the Order.
• Resolution of the Board of the National Bank of Ukraine “On Approval of the Regulation on Cash Operations in the National Currency in Ukraine” of 29 December 2017 No. 148: Clauses 11–15, 18, 23–29, 32, 39–43, 46, 49–50, and 53–54 of the Regulation.